If your product were audited, it would be tested as you sell it -- and if
that incorporated product D, it seems it would fail. As I understand
things, the entity which sells or places a product on the market is
responsible for its compliance; that would be you. So there's really
nothing for it but to market a compliant system. (That came out spelled
"complaint" -- a truly Freudian slip.)

Still, if you wish to market product "D", and if it really does fail, you
will have to either correct its problems or sell your equipment WITHOUT "D"
-- and let customers know that you are no longer able to provide it. 

As consumers, we must be satisfied with DoC's, but as a manufacturer -- and
legally liable reseller -- I'd want a copy of the test report.  Ask for a
copy of the test report from "D".  There is a possibility you are
over-testing; some of us overtest as insurance against audit failures.  It
may be that by using the (valid) methods they employ, the composite will
pass.  Of course, there is also the possibility they are under-testing, and
in this case, you could have their product retested and supply them with
results.  

If the supplier does provide you a copy of his test report, you will be
able to see how their test setup differs from your own, and (assuming that
it really does pass under the conditions used in that test) this will give
you valuable information as to the sources of failure.  There's a large
possibility that the difference is in the cables you each use. I'd look
long and hard at shield terminations. Pigtails are bad for compliance.
Bending mylar-foil shields also causes failures. Even the way cables are
laid up -- Cat I versus Cat V, for example -- can make a difference. 

And yes, the software used may cause repeatable differences. For example,
if you poll once every ten clock cycles,  and they poll once every hundred,
you have ten times the chance for immunity failure as they do. If they use
an error-correcting algorithm, and you do not, that will hide glitches. If
you use a regular, periodic "null signal" waveform, while they do not, you
will generate an emission -- where they don't. Opportunities to fail, as
you know, are Legion; they come not single spy, etc. 

Good luck!


Cortland

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